Henry C. Navarro v. Connie Gipson

CourtDistrict Court, C.D. California
DecidedSeptember 20, 2021
Docket5:21-cv-01529
StatusUnknown

This text of Henry C. Navarro v. Connie Gipson (Henry C. Navarro v. Connie Gipson) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Henry C. Navarro v. Connie Gipson, (C.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 EASTERN DIVISION 11 12 HENRY C. NAVARRO, ) No. ED CV 21-1529-SB (PLA) ) 13 Petitioner, ) ) 14 v. ) ORDER TO SHOW CAUSE RE: DISMISSAL ) OF HABEAS PETITION 15 ) CONNIE GIPSON, Secretary, CDCR, ) 16 ) Respondent. ) 17 ) 18 I 19 BACKGROUND 20 Henry C. Navarro (“petitioner”) initiated this action on September 7, 2021, by filing a Petition 21 for Writ of Habeas Corpus by a Person in State Custody pursuant to 28 U.S.C. § 2254 (“Petition”), 22 along with a Memorandum in Support of Habeas Petition (“Memorandum”) (ECF Nos. 1, 2). 23 Petitioner was convicted in 1998 of petty theft with a prior (Cal. Penal Code § 666). After 24 determining that petitioner had six prior serious or violent felony convictions, the trial court 25 sentenced him under California’s Three Strikes law to twenty-five years to life in state prison (Cal. 26 Penal Code §§ 667(b)-(i); 1170.12). (ECF No. 1 at 2). 27 On November 27, 2018, the Board of Parole Hearings (“BPH”) held petitioner’s initial parole 28 1 of danger to society or a threat to public safety. The BPH also determined that petitioner’s next 2 parole hearing would be in five years. (ECF No. 2 at 8, 39-41, 137-55). 3 Petitioner challenged the parole determination in a round of state habeas petitions.1 On 4 April 25, 2019, the San Bernardino County Superior Court issued a reasoned decision denying 5 relief, concluding that the BPH’s parole denial was supported by substantial evidence and that, 6 to the extent petitioner was contending his sentence was unconstitutionally disproportionate to his 7 criminal conduct, his “conclusory assertion of disproportionality [was] insufficient given how well 8 established it is that lengthy sentences under the Three Strikes law do not amount to cruel and 9 unusual punishment.” (ECF No. 2 at 187 (citing Ewing v. California, 538 U.S. 11, 17-19, 29-31, 10 123 S. Ct. 1179, 155 L. Ed. 2d 108 (2003))). On September 19, 2019, the California Court of 11 Appeal denied habeas relief. (ECF No. 2 at 190). On March 11, 2020, the California Supreme 12 Court denied petitioner’s habeas petition without prejudice to him filing another petition after In re 13 Palmer, case number S256149, was decided. (ECF No. 2 at 192). 14 On January 28, 2021, the California Supreme Court issued its decision in In re Palmer, 10 15 Cal. 5th 959, 968, 970, 274 Cal. Rptr. 3d 292 (2021), holding that inmates who are denied parole 16 but believe their confinements have become constitutionally excessive as a result, are allowed to 17 challenge their confinements as cruel or unusual under the California Constitution. Following the 18 Palmer decision, petitioner filed another habeas petition in the California Supreme Court, which 19 was summarily denied on May 12, 2021. (ECF No. 2 at 194). 20 In the instant Petition, petitioner asserts that, after the BPH denied parole, his sentence 21 became constitutionally excessive, and that the superior court in its reasoned decision denying 22 habeas relief only evaluated the lawfulness of petitioner’s sentence “as imposed,” and failed to 23 consider whether the BPH abused its discretion by denying release given that petitioner has been 24 incarcerated since January 1997. (ECF No. 2 at 6, 11-12, 14). 25 / 26 / 27 28 1 II 2 DISCUSSION 3 A district court may summarily dismiss a habeas corpus petition “[i]f it plainly appears from 4 the petition and any attached exhibits that the petitioner is not entitled to relief in the district court.” 5 Rule 4 of the Rules Governing Section 2254 Cases; see also Hendricks v. Vasquez, 908 F.2d 490, 6 491 (9th Cir. 1990). Following a preliminary review of the Petition and Memorandum, it appears 7 that dismissal of the Petition is warranted as petitioner’s Eighth Amendment challenge is either 8 not cognizable or is successive. 9 Petitioner asserts that, based on the BPH’s decision to deny release on parole, his 10 sentence has become excessively long in violation of the Eighth Amendment’s ban on cruel and 11 unusual punishment. This claim fails for several reasons. First, to the extent petitioner is attacking 12 the BPH’s parole denial itself, the Supreme Court’s decision in Swarthout v. Cooke, 562 U.S. 216, 13 131 S.Ct. 859, 178 L.Ed.2d 732 (2011), bars substantive parole challenges. The Cooke Court 14 explained that a federal court’s inquiry into a state prisoner’s parole denial is limited to determining 15 whether the following procedural safeguards, as set forth in Greenholtz v. Inmates of Neb. Penal 16 & Corr. Complex, 442 U.S. 1, 99 S. Ct. 2100, 60 L. Ed. 2d 668 (1979), were satisfied: that the 17 prisoner “was allowed an opportunity to be heard and was provided a statement of the reasons 18 why parole was denied.” Cooke, 562 U.S. at 220 (citing Greenholtz, 442 U.S. at 16). Cooke was 19 “unequivocal in holding that if an inmate seeking parole [received the safeguards under 20 Greenholtz], that should be the beginning and the end of the inquiry into whether the inmate 21 received due process.” Pearson v. Muntz, 639 F.3d 1185, 1191 (9th Cir. 2011) (quoting Cooke, 22 562 U.S. at 220) (internal quotations, alterations, and ellipsis omitted). Here, it does not appear 23 that petitioner alleges he was in any way deprived of the opportunity to speak at his November 24 2018 parole hearing and contest the evidence against him, or that the BPH failed to provide him 25 the reasons why parole was denied. Under Cooke, the Court lacks the authority to consider parole 26 challenges that exceed the scope of these minimal due process protections. Accordingly, to the 27 extent petitioner contends the BPH improperly found him unsuitable for parole, his claim is not 28 cognizable and cannot be considered on federal habeas review. 1 Petitioner’s Eighth Amendment challenge based on the parole denial is similarly unavailing. 2 The Supreme Court in Greenholtz held that “[t]here is no constitutional or inherent right of a 3 convicted person to be conditionally released before the expiration of a valid sentence.” 4 Greenholtz, 442 U.S. at 7. Petitioner does not cite, and the Court is not aware of, any clearly 5 established federal law holding that, for inmates serving indeterminate life sentences, continued 6 confinement following a denial of release on parole may violate the Eighth Amendment.2 Thus, 7 on federal habeas review, if an indeterminate life sentence is constitutional when it was imposed, 8 it cannot be found to be unconstitutional simply on the basis that the petitioner is forced to remain 9 incarcerated until the expiration of the term of imprisonment. See Tatum v. Chappell, 2015 WL 10 1383516, at *3 (C.D. Cal. March 24, 2015) (“[N]o clearly established Supreme Court authority 11 holds that the denial of parole . . . to a prisoner who is serving an indeterminate life sentence could 12 render an otherwise constitutional sentence cruel and unusual punishment.”). Indeed, numerous 13 federal courts faced with similar Eighth Amendment challenges have rejected such claims as not 14 cognizable.3 See, e.g., Brooks v. Borders, 2018 WL 5098858, at *3 (C.D. Cal. Feb. 13, 2018) 15 (finding no cognizable claim where the petitioner alleged that parole denial was “tantamount to 16 cruel and unusual punishment in violation of the Eighth Amendment”), Report and 17 Recommendation accepted, 2018 WL 5095159 (C.D. Cal. Oct. 17, 2018); Molina v.

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Related

Ewing v. California
538 U.S. 11 (Supreme Court, 2003)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
Burton v. Stewart
549 U.S. 147 (Supreme Court, 2007)
Purcell v. Gonzalez
549 U.S. 1 (Supreme Court, 2006)
Pearson v. Muntz
639 F.3d 1185 (Ninth Circuit, 2011)
In re Palmer
479 P.3d 782 (California Supreme Court, 2021)
Swarthout v. Cooke
178 L. Ed. 2d 732 (Supreme Court, 2011)

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Bluebook (online)
Henry C. Navarro v. Connie Gipson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henry-c-navarro-v-connie-gipson-cacd-2021.